UFLPA forced-labor detentions spiked 51% to 7,325 shipments in FY2025, with a 77% denial rate for Chinese shipments and no clear standard for what evidence clears your goods

CBP stopped 7,325 shipments for review under the Uyghur Forced Labor Prevention Act in fiscal year 2025, a 51% increase over FY2024's 4,850 shipments. For shipments originating directly from China, the denial rate spiked to 77%, up from approximately 60% in 2024. The UFLPA Entity List grew to 144 Chinese entities, and enforcement expanded to new sectors: lithium-ion batteries, copper, steel, PVC, and aluminum were all designated as high-priority in August 2025. This matters because when CBP detains a shipment under UFLPA, the importer must prove by "clear and convincing evidence" — the highest civil standard of proof — that no forced labor was involved anywhere in the supply chain. This is the legal equivalent of proving a negative. An importer of aluminum components must trace the raw bauxite through smelting, refining, and fabrication, proving at every stage that no entity on the UFLPA Entity List was involved and no Xinjiang-origin inputs were used. For products with complex, multi-tier supply chains — electronics, automotive parts, solar panels — this is functionally impossible without months of investigation and tens of thousands of dollars in consulting fees. Meanwhile, the detained goods sit in a bonded warehouse accruing storage charges of $180-$430 per day. The Ninestar Corp. v. United States decision confirmed that CBP needs only "reasonable cause" to detain, while the importer bears the full burden of rebuttal. There is no published standard for what documentation CBP considers sufficient. Importers report submitting hundreds of pages of supply chain documentation — factory audits, bills of materials, polysilicon lot numbers, shipping records — only to receive a one-line denial with no explanation of what was missing. This problem persists because forced-labor compliance requires visibility into supplier tiers that most companies simply do not have. A typical manufacturer knows its Tier 1 supplier. Knowing Tier 2 (the supplier's supplier) is difficult. Knowing Tier 3 and beyond — where raw materials like polysilicon, lithium, or cotton originate — is nearly impossible without a dedicated compliance infrastructure that costs six to seven figures to build. CBP has expanded enforcement beyond Xinjiang, issuing Withhold Release Orders on products from Mexico, Taiwan, and Mauritius in FY2026, meaning the geographic scope of compliance is now global.